COMMISSIONER OF INCOME-TAX, MADRAS vs S. RAMAN CHETTIAR

The Supreme Court held that the first return submitted by the assessee was valid under Section 22(3) of the Indian Income-tax Act, 1922, and that the Department could not ignore it to issue a notice under Section 34. The Court clarified that a return filed before a valid notice under Section 34 must be treated as valid, regardless of the initial notice's validity. The judgment of the Madras High Court was reversed, and the reassessment under Section 34 was deemed invalid, overruling R. K. Das & Co. v. Commissioner of Income-tax, West Bengal (1956) 30 I.T.R. 439.